Published name
Upload a submission
6th April 2022
GEMS Issues Paper:
Televisions, Computer Monitors and Signage Displays
Australian Government Department of Industry, Science, Energy and Resources
Dear Sir/Madam,
CESA comments on the Televisions, Computer Monitors and
Digital Signage Displays
Issues Paper - February 2022
The Consumer Electronics Suppliers Association (CESA) welcomes the opportunity to make
a submission on the above Issues Paper.
CESA is the premier national, industry body in Australia representing suppliers of consumer
electrical and electronic appliances and equipment. Members of CESA include major global
suppliers of products such as televisions, home entertainment products, computers,
computer monitors, whitegoods, cooking appliances, gas appliances, small appliances,
accessories, and air conditioning equipment.
General Comment
CESA supports the Departments review of the MEPS and Labelling requirements for
televisions and computer monitors and welcomes the discussion on the inclusion of digital
signage displays.
CESA has been advocating a review into the existing GEMS determination for televisions for
some time now as the current arrangements are no longer appropriate given the substantial
technology advancements and diversity that had occurred since the program commenced in
2009.
CESA members have indicated a preference to follow the European approach for the simple
fact that televisions on sale in Australia and New Zealand are designed to operate on a
230 V 50 Hz mains supply and receive broadcast signals using the DVB digital television
system. Digital display screens placed on the Australian and New Zealand market are
typically based on European designs and generally have minor software changes for
adaption to the Australian and New Zealand local requirements.
Following the IEC standards for energy consumption testing will reduce costs and allow
continued adoption of European models into our market.
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 2 of 7
To Answer the Specific Questions
5.1 Scope of efficiency regulations
1) What issues need to be considered if the scope of the existing television MEPS
and labelling is expanded to include digital signage displays and computer
monitors?
Digital signage monitors are used in public spaces often in high ambient light
situations including broad daylight. Their energy needs are different and
generally higher that other digital displays. They need to be considered
separately to consumer products and certainly can’t be included in a rating
system which rewards displays when the brightness is reduced. The brightness
of the image on the screen in many cases is determined by the environment
they are designed to operate in. High ambient light environments require
additional component protection which can involve complicated and energy
intensive cooling systems to maintain reliability and durability.
Computer monitors for domestic use are increasingly being used to view
streamed video content and could be considered for inclusion in the scope of
the television MEPS and labelling. Computer monitors use similar technology to
televisions and therefore the larger models are not too dissimilar to televisions.
Further consultation should be undertaken to identify a cut off for such
inclusion. Smaller screen desktop computer monitors should remain under a
separate MEPS and labelling scheme as their usage and energy consumption is
very different to the larger general use monitors.
2) What data is available for televisions, computer monitors and digital signage
displays that could be used in the consultation RIS?
Not able to offer comment.
3) Are there any particular products or categories that should be excluded, for
example specialist medical displays?
Alignment with the EU exemptions, professional displays, broadcast displays,
security displays, digital interactive whiteboards, digital photo frames control
panels etc. Digital projects should also be exempt.
4) One option to expand the scope could be to regulate ‘digital screens’ and use
exclusions to remove specific products. Are there any concerns with this
approach?
I would be caution of this approach, new technologies would be disadvantaged
with such an approach. New technologies using ‘digital screens’ should be
assessed for their suitability for inclusion, not automatically included.
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 3 of 7
5) Are there any other technologies that should be considered for inclusion or
exclusion in the scope?
An exemption should be considered for special display screens such as video
walls, tiled displays and 3D display.
5.2 MEPS levels
6) What issues need to be considered if the 2021 or 2023 EU Ecodesign levels
were adopted for televisions and computer monitors?
Industry needs sufficient notice and a transition to the requirements. Our
preference is to align with the EU MEPS requirements. CESA requests a staged
approach where 2021 MEPS is regulated initially with a later adoption of the
2023 MEPS 12 months after the EU implementation. Moving to 2023 EU will
result in a loss of brand/models in the market resulting in less selection and
competition and a higher average purchase price.
New model televisions are usually introduced into the market in the first half of
the year so we would request regulations come into force on 1st October of the
nominated year.
7) The EU Ecodesign regulations do not include MEPS levels for signage displays.
Should Australia and New Zealand apply MEPS to this product?
No, as explained in our response to question 1), signage displays are designed
to operate at high brightness levels and include additional componentry to
maintain reliability which are not related to the generation of the image on the
screen. To try and incorporate a MEPS level would be complicated and would
have to accommodate numerous environmental factors which greatly impact
the energy consumption of the display. On the other hand, televisions and
computer monitors are operated in relatively stable environmental situations
where the energy consumption is not dependant on the environment.
8) Are there more appropriate MEPS levels that should be considered in the RIS
process?
An increase beyond EU 2021 will become a barrier to the market and will
result in a reduced range of products on the market. This should be
considered with further industry consultation.
Screen resolution
9) What level of MEPS would be appropriate for 8k televisions? Are there any
issues in including 8k televisions in a new efficiency regulation?
The introduction of MEPS for 8k televisions should follow the EU regulations,
initially no MEPS requirement when aligning with 2021 EU, then introduction
when 2023 EU requirements are introduced.
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 4 of 7
10) Do you have any data or information about the expected future market for 8k
televisions?
8k digital displays is the next evolutionally step in the quest for an image
which contains finer pixels and hence a more realistic image. 8k will most likely
never be broadcast terrestrially in this country and only accessed via an
internet connection in the domestic environment. Technology marches on and
at some point in the future consumers will be left with few choices other than
to purchase a ultra-high definition display of 4k or 8k resolution, whether they
have a need or not. The technology is viable and therefore will proliferate at
some point in the future.
Automatic brightness control for digital screens
11) What issues need to be considered if the 10% reduction in measured energy
consumption is adopted for digital screens with active ABC?
With reference to the 2021 EU regulation, consider removing requirement (d).
(d) with ABC enabled, the measured value of the on mode power must decrease by
20 % or more when the ambient light condition, measured at the ABC sensor, is
reduced from 100 lux to 12 lux; and
It is difficult to achieve the 20% reduction especially for small screen models
up to about 40 inches. Since smaller screen models have lower power
consumption, achieving a 20% reduction will be difficult.
12) Which local factors for ABC should be considered in the consultation RIS?
No comment
13) Are there any other allowances that should be considered for different types of
screens?
Allowances should be included for technologies that contribute to energy
efficiency such as LED backlight dimming control, OLED, Micro LED and so on.
5.3 Energy Rating Labelling
14) What issues need to be considered when assessing these two options for
energy rating labelling? Will these options work equally well for signage
displays and computer monitors?
The Energy Star regulation passes only the top 25% of products in US market
and it is a voluntary scheme. Therefore, considering Energy Star as mandatory
scheme would not be appropriate.
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 5 of 7
CESA prefers the EU approach as noted previously and recognises that the EU
are looking at an alignment with CTA-2037-C in the future where light
production is taken into account.
Moving to a light production measurement method introduces another level of
complexity. The generation of white light is relatively easy for any digital
display, the challenge of resent years it to produce a digital display that can
achieve the same colour Gamut of a phosphor-based CRT or Plasma display.
To achieve a wide colour gamut result, poor energy efficiency of white
production is the by-product. The primary colours on a wide gamut display are
much deeper and hence less luminous. Cutting edge consumer digital displays
have a number of colour gamut specifications which relate to the size of the
colour pallet. A great amount of consideration will be required to ensure that
wide colour gamut displays are not disadvantaged when a light production
measurement calculation is made.
Wide colour gamut monitors are becoming commonplace, so the same
consideration is required if light production is included in the energy efficiency
calculation.
Regarding measurement method, it should be noted that the latest IEC and
CTA-2037-C are still under study with lobbying.
15) Should multiple Preset Picture Settings in an overall efficiency metric be
included to give a more balanced measure of television performance? If so,
should these Preset Picture Settings be evenly weighted?
Customers have been known to rarely change the settings on their television,
the default (out of the carton setting) is the setting most commonly used. For
this reason, only the default setting should be used in the efficiency metric.
Once the metric matures to include light production the efficiency calculations
will follow this change.
16) Are there any issues with using efficiency of light production from the
television screen as the key measure?
Please refer to my comments in question 14.
The technology employed in high performance models requires higher fixed
power consumption and therefore disparity arises in the efficiency between
low end and high end models. The driving force in digital screen design is to
recreate a natural image with natural colour performance. While this was
easily achievable with phosphor based technologies digital screens have
struggled to come even close to that performance. A new colour space called
sRGB was developed so that digital devices, cameras, printers and displays
could provide consistent image colour. This colour space was initially adopted
by large digital screens which fell far short of the traditional colour
performance afforded by the CRT display. Entry level televisions today still
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 6 of 7
employ sRGB spec screens which are capable of producing white light far more
efficiently that wide colour gamut high end digital displays.
Fixed power consumption needs to he evaluated, and allowances made across
the screen technologies. Colour gamut performance must also be considered.
17) Should ABC controls be rewarded in an energy rating labelling algorithm?
Should each illuminance level be equally weighted (as per ENERGY STAR) or is
there a more relevant weighting to reflect usage conditions in Australia and
New Zealand? (Note: local weighting would not change the measurement
method.)
ABC should be rewarded as is contributes to energy efficient operation of the
digital display. Our preference is to the EU scheme.
18) Which local factors for ABC should be considered in the consultation RIS?
Alignment with the EU is the best practice, to introduce local factors is a
departure from global standards making Australia different.
19) Are there any other allowances that should be considered for different types of
screens?
Covered in previous answers.
20) Are there any other star rating issues that need to be considered?
No comment
Hours of operation
21) What hours of operation should be considered for televisions, computer
monitors and signage displays? Please supply information or data to support
your answer.
I don’t have any relevant data to provide. Signage displays vary in operation
from business hours to 24 hr operation.
Displaying labels
22) How should labels be displayed in show rooms and shops?
Both physical and electronic labelling should be permitted.
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
Page 7 of 7
5.4 Test method standard
23) What issues need to be considered if the European Ecodesign test method
(CENELEC EN 62087 Parts 1 to 3 (2016)) was adopted by Australia and New
Zealand for both MEPS and labelling?
CENELEC EN 62087 Parts 1 to 3 (2016) cannot measure HDR.
The measurement would be related to SDR content.
24) What issues need to be considered if the US CTA-2037-C test method was
used to underpin energy rating labelling in Australia and New Zealand, and the
EU Ecodesign test method (CENELEC EN 62087 Parts 1 to 3 (2016)) for the
MEPS levels?
It would cause additional testing due to different measurement methods.
Energy rating labelling and MEPS calculations should refer to the same
standard.
5.5 Cost benefit analysis
25) Are there any modelling assumptions listed in Appendix B with which you
disagree? If so, what assumptions should be used instead? Please provide any
supporting information or data.
No comment
Yours sincerely,
Stuart Parker
General Manager
Consumer Electronics Suppliers Association
stuart.parker@cesa.asn.au
CESA PO Box 250 Avoca Beach NSW 2251 Tel: 0411 627 270
ABN: 34 065 208 531 www.cesa.asn.au
